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B. 2003 Taxable Year
I. $71,200 Loss
In general, a taxpayer’s “loss of time” or “value of his
time” is not deductible as a casualty loss or otherwise. Cf.
Pfalzgraf v. Commissioner, 67 T.C. 784 (1977) (stating that in
using a valuation method to compute a loss for purposes of
section 165, the value of a person’s “loss of time” cannot be
included in the computation); Wilhelm v. Commissioner, T.C. Memo.
1991-513 (disallowing a taxpayer’s “time spent” handling an
estate from his net operating loss computation); O’Connor v.
Commissioner, T.C. Memo. 1981-151 (disallowing a taxpayer’s
deduction for the uncompensated “value of his time” as a
classroom expense and a job-related expense). The disallowance
of a claimed deduction arising from the taxpayer’s loss of time
or the value thereof results from the fact that he has not
included any amount in gross income, and therefore, he has no tax
cost basis in the item that he can deduct. See Hutcheson v.
Commissioner, 17 T.C. 14, 19 (1951).
Petitioner testified that his itemized deductions
represented, in part, a $71,200 casualty or damages for his time
fighting crime and criminals and defending himself and his
business pro se in the courts against the Government. Petitioner
concluded that since attorneys are paid “when [they] practice in
the court,” he too should be similarly compensated or rewarded
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